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Vessel General Permit (VGP) 2013
This section aims to provide you with the necessary information on the US Environmental Protection Agency (EPA)'s Vessel General Permit (VGP) which will come into force on 19 December 2013.
The US Environmental Protection Agency (EPA) has confirmed a revised Vessel General Permit (VGP) will come into force on 19 December 2013.
The new VGP, will apply to non-recreational vessels that are 79 feet (24.08 meters) and greater in length that enter US waters. For these vessels, the VGP requires environmentally acceptable lubricants (EALs) to be used in all applications that have the potential for an "oil-to-sea" interface, unless technically infeasible.
The VGP states that oil-to-sea interfaces include any mechanical or other equipment where seals or surfaces may release small quantities of oil into the sea. The VGP specifically identifies applications that have the potential for an oil-to-sea interface as:
- Controllable Pitch Propeller
- Thruster Hydraulic Fluids
- Other oil-to-sea interfaces including lubrication discharges from:
- Paddle wheel propulsion
- Stern Tubes
- Thruster Bearings
- Rudder Bearings
- Azimuth Thrusters
- Propulsion Pod Lubrication
- Wire Rope
- Mechanical equipment subject to immersion (e.g. dredges, grabs, etc)
The revised VGP requires that all vessels must use EALs in their oil-to-sea interfaces unless it is technically infeasible to use them in existing equipment. The permit does not require that vessel machinery or equipment be retrofitted to accept EAL.
For requirements related to EALs, the VGP defines “technically infeasible” as where:
- No EAL products are approved for use in a given application that meet manufacturer (OEM) specifications for that equipment
- Products which come pre-lubricated (e.g. wire ropes) and have no available alternatives manufactured with EALs
- Products meeting a manufacturers (OEM) specifications are not available within any port in which the vessel calls
- Change over and use of an EAL must wait until the vessel's next scheduled dry docking (consistent with the requirements of 46 CFR 31.10-21, typically at least every 5 years or sooner)
If a vessel is unable to use an EAL because it is technically infeasible, the owner/operator must explain why they cannot do so in their vessel recordkeeping documentation, and must report the use of a non-environmentally acceptable lubricant to EPA in the vessel’s Annual Report.
According to the new VGP, “environmentally acceptable lubricants” means lubricants that are “biodegradable” and “minimally-toxic” and are not “bioaccumulative”, meeting performance standards that have been defined by the EPA. For purposes of the VGP, products meeting the permit’s definitions of being an “Environmentally Acceptable Lubricant” include those labelled by the following labelling programs: Blue Angel, European Ecolabel, Nordic Swan, the Swedish Standards SS 155434 and 155470, Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) requirements, and EPA’s Design for the Environment (DfE).
Shell Marine Products is committed to providing practical and cost effective solutions to our customers to help them comply with the requirements of the new VGP regulations.
We will progressively enhance our product portfolio to include EALs for use in applications with potential for an oil-to-sea interface. More detailed information about our new EAL products will be made available soon, including from where and when they will be available.
We understand that some customers may be interested to start using EALs in the short term due to either dry docking schedules or New Build project construction timetables. Please be assured that we will work with all our customers to help meet their needs in relation to the VGP.
It should be noted, however, that according to the VGP:
- Vessels do not have to start using EALs before 19th December 2013
- Where dry-docking is required to changeover to an EAL, a vessel can continue to use a non-VGP compliant lubricant until the next scheduled dry-docking, even if this falls after 19th December 2013
Our technical advisors will also be available to help our customers verify applications and installations which require EALs, identify specific EAL product requirements, provide a list of recommended products to meet the VGP regulation, and provide expert advice for managing lubricants change over.
Where required, Shell Marine Products will also provide our customers with the necessary documentation to validate that there are no technically feasible EALs in the market that are compatible with equipment and installations on their vessels, based on our access to information from OEMs.